Banking restrictions and IBAN discrimination: the position of the Luxembourg government

In response to a parliamentary enquiry by MP Sven Clement, Finance Minister Gilles Roth confirmed: refusing to allow banks to fulfil SEPA transfers to accounts in other EU countries, if based only on a "foreign IBAN", contravenes EU Regulation 260/2012 and the principle of non-discrimination.

According to the minister, a bank has the right to refuse a transfer only if there are justified technical reasons regulated by the European Payments Council (EPC) "R-transactions" codes. References to these regulations are provided in an official document (see EPC Reason Codes).

IBAN discrimination, where companies are denied service because of a "foreign" account number, is a problem both in Luxembourg and at EU level. However, the CSSF (financial supervisor) recorded only one case of a complaint of such discrimination in 2024 and none in 2025.

Additionally, the Minister commented on the information about "excessive fees" - up to 12,500 euros - allegedly charged by banks when an account is not closed in time after forced cancellation. Such cases have not been officially confirmed and the CSSF has not received any complaints.

The government stresses that it does not interfere in the commercial policies of banks, but is in constant dialogue with the financial sector to ensure that businesses have access to banking services regardless of the nationality of the beneficial owners (UBOs).

In conclusion, the Minister said that despite the risks of reputational losses, Luxembourg will continue to develop the financial sector, especially in the field of alternative investments and private equity, within the framework of the Ambitions 2030: Shaping Finance for our Future programme.